Effective Date: ‘evision No, |Document No. [Page No.
September 29, 2006 0 SCA-TR-TASK1-0013 22 of 115

The use of such maximized (or upper-bound) values, however, is limited to those instances
where the resultant maximized doses yield POC values below 50%, which are not compensated.
For this second category, the dose reconstructor needs only to ensure that all potential internal
and external exposure pathways have been considered.

reconstruction is efficiency, which is achieved by the fact that maximized doses avoid the need ‘Y
for precise data and eliminates consideration for the uncertainty of the dose. Lastly, the use of
jounding values in dose reconstruction minimizes any controversy regarding the decision not to
compensate a claim.

\es obvious benefit of “worst-case” assumptions and the use of maximized doses in dose

Although simplistic in design, to satisfy this type of a dose reconstruction, the TBD must, at a ;
minimum, provide information and data that clearly identify (1) all potential radionuclides, i
(2) all potential modes of exposure, and (3) upper Jimits for each contaminant and mode of
exposure. Thus, for external exposures, maximum dose rates must be identified in time and
space that correspond to a worker’s employment period, work locations, and job assignment;

| similarly, in order to maximize internal exposures, highest air concentrations and surface

u contaminations must be identified.

Category 3: This represents the most complex and challenging dose reconstruction category. It
consists of claims where the case cannot be dealt with under one of the two categories above.
For instance, when a minimum dose estimate does not result in compensation, a next step is
required to make a more complete estimate. Or when a “worst-case” dose estimate that has
assumptions that may be physically implausible results in a POC greater than 50%, a more
refined analysis is required. A more refined estimate may be required either to deny or to
compensate. In such dose reconstructions, which may be represented as “reasonable,” NIOSH
has committed to resolve uncertainties in favor of the claimant. According to 42 CFR Part 82,
NIOSH interprets “reasonable estimates” of radiation dose to mean the following:

... estimates calculated using a substantial basis of fact and the application of
science-based, logical assumptions to supplement or interpret the factual basis.
Claimants will in no case be harmed by any level of uncertainty involved in
their claims, since assumptions applied by NIOSH will consistently give the
benefit of the doubt to claimants. [Emphasis added.]

In order to achieve the five objectives described above, SC&A reviewed each of the six TBDs,
their supplemental attachments, and TIBs, giving due consideration to the three categories of
dose reconstructions that the site profile is intended to support. The six ORNL TBDs provide
well-organized information for the dose reconstructor when adequate data were available to do
that comprehensively.

ORAUT-TKBS-0012-1, Rev. 00, Technical Basis Document for Oak Ridge National Laboratory
— Introduction (Burns 2004a), explains the purpose and the scope of the site profile. SC&A was
attentive to this section, because it explains the role of each TBD in support of the dose
reconstruction process. During the course of its review, SC&A was cognizant of the fact that the
site profile is not required by the EEOICPA or by 42 CFR Part 82, which implements the statute.


Table V: Parameter Estimates for the Main Effects Model for Mortality from Selected Cancer Causes of Death
Among White Males (N = 67,197) Who Worked in Oak Ridge Between 1943 and 1984
meget Tent!

Felis?
SES* Employment”
LRT’ (Monthly) {<1 Year) {% per Year)

Couse of Death Observed
_GCDA-8) Number__SMR___X10__TEC __Yi2__K25_ MUL
281 62F 0.58 0.16)
050099)
055 32)
By

AM Cancer 4673

-PE-

‘Other Lymphatic (202,203, 208)
The “faciny” factor is used as the reference category so that the firs five parameter estimates (colmmn 4-8) are the natural logarithms of the SMRs in loganthmic percent (L%) units atthe reference

level of SES and length of employment atthe midpoint (1965) of period of follow-up,
The reference category for SES is the non-monthly (vs. monthly) workers, and the reference level for length of employment is greater than one year. The parameter estimates for SES, and length of

are sugatcant 05 level)
employment ar log relative isk in 34a, These estimates can be cormpored withthe nul value zero sing the SEs glen in patenthess, or conteried ina estimates of relative isk
The period trend describes the change in the SMR (percent per yeat) over the forty years of follow-up.

er statistic is chi-square (with 4 degrees of freedom) forthe mall hypothesis of no differences the facility effects adjusted for SES, leogth of employment, and period trend (values that exceed 9.49



Effective Date: Revision No. [Document No. Page No.
September 29, 2006 0 SCA-TR-TASK1-0013 10 of 115

The operation of the Graphite Reactor for producing plutonium and other 4

{
radioisotopes
7

The development and refinement of chemical processes to separate
plutonium, uranium, and thorium from irradiated fuel

Chemical separation of RaLa from irradiated fuel slugs for use in
implosion dynamics studies at Los Alamos National Laboratory

oe Stanger

Operation of facilities for the separation, packaging, and distribution of i
radioisotopes for government and commercial use

In addition, ORNL developed new reactor technologies. The Laboratory tested
different reactor designs (pool, pressurized-water, boiling-water, liquid-metal, t
4 as-cooled) that were either scrapped or developed further elsewhere. Reactors
‘operated at ORNL include the Low-Intensity Test Reactor (LITR), Critical 7
\Experiments Facility [CEF, at the Y-12 National Nuclear Security Complex
1 -12)], Bulk Shielding Reactor (BSR)/Pool Critical Assembly (PCA), Oak Ridge ‘;
Research Reactor (ORR), Tower Shielding Reactor (TSR), Health Physics a
‘Research Reactor (HPRR), Homogeneous Reactor Experiment (HRE), Aircraft |:
Nuclear Propulsion (ANP) Program, the High Flux Isotope Reactor (HFIR), and |
{the Molten Salt Reactor Experiment (MSRE).

SC&A’s review focused on the six TBDs that make up the ORNL site profile. These address
introduction, site description, occupational internal dose, occupational external dose,
occupational medical dose, and occupational environmental dose, as they pertain to historic
radiation exposure of ORNL workers. These TBDs are dated from 2004-2006. As “living”
documents, TBDs are constantly being revised as new information, experience, or issues arise.
A complete list of the ORNL TBDs, as well as supporting documents, that were reviewed by
SC&A is provided in Attachment 1.

SC&A’s review process included a review of the TBDs, a visit to Oak Ridge, Tennessee, to {
conduct interviews with site experts and identify documents for data retrieval, reviews of 4
retrieved ORNL and other historic records, and an exchange of questions and answers, in
addition to TBD-specific conference calls, between SC&A and its NIOSH and Oak Ridge

i

Associated Universities (ORAU) counterparts. The TBDs were evaluated for their
‘completeness, technical accuracy, adequacy of data, compliance with stated objectives, and

jconsistency with other site profiles, as stipulated in the SC&A Standard Operating Procedure for | 4
i | Performing Site Profile Reviews (SC&A 2004).

The Occupational Medical Dose TBD, ORAUT-TKBS-0012-3 (Fleming 2004), provides little
documentation to support the assumed techniques, and protocols applied to calculate the dose,
which is mainly derived from Cardarelli et al. 2002, are accurate. NIOSH believes that when no
| information is readily available about the energy spectrum, it is reasonable to use the i
; { assumptions for dose conversion factors (DCFs) that are presented in the Implementation Guide. *

§
:
i



Rffective Date: [Revision No. {Document No. age No.
September 29, 2006 i) SCA-TR-TASK1-0013 63 of 115

REFERENCES

42 CER Part 82, Title 42, Public Health, Part 82, Methods for Radiation Dose Reconstruction
Under the Energy Employees Occupational Illness Compensation Program Act of 2000, Code of
Federal Regulations, May 2, 2002.

Berger, C. D., 2003, Personal conversation discussing the operation of the WBC facility during
the late 1970s and early 1980s, November 2003.

Bollenbacher, M., Fleming, K, Joyce, B., 2006, Technical Basis Document for the Oak Ridge
National Laboratory - Occupational Internal Dose, ORAUT-TKBS-0012-5, Rev. 00 PC-1, Oak
Ridge Associated Universities, Oak Ridge, Tennessee, May 30, 2006.

Brackett, E.M., and Bihl, D.E., 2005, Internal Dose Overestimates for Facilities with Air
Sampling Programs, ORAUT-OTIB-0018, Revision 01, Oak Ridge Associated Universities, Oak
Ridge, Tennessee, August 9, 2005.

Bradley, J.E., 1945, Personnel Monitoring of Fast Neutron Exposure, Memorandum from J.E.
Bradley to K.Z. Morgan dated April 13, 1945, Oak Ridge National Laboratory, Oak Ridge,
Tennessee,

Brown, P.E., Davis, D.M., and Henley, L.C., 1957, A Current Review of Body Fluid Analysis,
Procedures, and Method of Reporting, Oak Ridge National Laboratory, Oak Ridge, Tennessee,
January 1957.

Bums, R. E., 2004a, Technical Basis Document for the Oak Ridge National Laboratory —
Introduction, ORAUT-TKBS-0012-1, Rev. 00, Oak Ridge Associated Universities, Oak Ridge,
Tennessee, August 11, 2004,

Bums, R. E., 2004b, Technical Basis Document for the Oak Ridge National Laboratory —
Occupational Environmental Dose, ORAUT-TKBS-0012-4, Rev. 00, Oak Ridge Associated
Universities, Oak Ridge, Tennessee, May 7, 2004.

Burns, R. E., and Mohrbacher J., 2004, Technical Basis Document for the Oak Ridge National
Laboratory — Occupational External Dose, ORAUT-TKBS-0012-6, Rev. 00, Oak Ridge
Associated Universities, Oak Ridge, Tennessee, August 11, 2004.

Cardarelli, J. H., Spitz, C., Rice, C., Buncher, R., Elson, H., and Succop, P., 2002. Significance
of Radiation Exposure from Work-Related Chest X-Rays for Epidemiological Studies of
Radiation Workers, Amer. J. of Indust. Med. 42-490-501

Chen, J. I. and McDowell-Boyer, L., 2004, Technical Basis Document for the Los Alamos
National Laboratory — Occupational Environmental Dose, ORAUT-TKBS-0010-4, Rev. 00, Oak
Ridge Associated Universities, Oak Ridge, Tennessee, October 8, 2004.


Dose Estimate

External Dose -
External dose is received from radiation originating outside the body and is typically measured

by dosimetry worn on the body. Such radiation doses may have been delivered quickly (acute

exposure) or slowly over the period of time that the employee was exposed (chronic exposure).
External doses for individuals not monitored for radiation exposure were likely predominantly

from on-site ambient photon radiation and occupational medical X-ray procedures.

Radiation Type, Energy, and Exposure Geometry
Due to the fact that ‘was not monitored, the determination of radiation exposure

geometry was not necessary for this reconstruction. For the purposes of estimating probability
of causation, all on-site ambient photon doses and medical X-ray doses are assumed to be acute.
Additionally, to maximize the probability of causation, the photon energy range was always
assumed to be 30-250 keV.

On-Site Ambient Dose
Because was not monitored for ionizing radiation doses during his employment at

X-10 and Y-12, on-site ambient doses were assessed as part of this reconstruction in accordance
with the External Dose Reconstruction Implementation Guideline? This accounts for any doses
from stack releases or other radiation sources that may have been unmonitored at the site.

The on-site ambient doses assigned were based on a comparison between the Technical Basis
Document for Oak Ridge National Laboratory — Occupational Environmental Dose’ and the
Technical Basis Document for Y-12 National Security Complex — Occupational Environmental
Dose.® The higher ambient dose was attributed to X-10 and the doses were doubled to ensure the
final dose is maximized. This results in a total on-site ambient dose of 1.456 rem each to the
bladder and prostate would not have been present in an environment providing
‘doses this high due to the nature of his work as a security inspector.

Occupational Medical Dose ,

Although may not have been required to undergo medical X-ray procedures, the
dose received from diagnostic X-ray procedures that may have been required as a condition of
employment was also included in the overall dose to the bladder and prostate (using the bladder
as a surrogate organ for the prostate). 10 Based on information in the Technical Basis Document
for the Oak Ridge National Laboratory — Occupational Medical Dose’ and the Technical Basis
Document for the Y-12 National Security Complex — Occupational Medical Dose,$ and an
assumed annual X-ray each year of employment, a total X-ray dose of 0.065 rem was assigned to
each cancer location. This X-ray dose is considered claimant favorable as it likely exceeds the
true X-ray dose to the bladder and prostate. Additionally, a multiplication factor of 1.3 has been
applied to ensure claimant favorability and to account for uncertainty.

Internal Dose
Internal dose is caused by radioactive materials that are taken into the body. A chronic intake is

an intake of radioactive material that occurs over an extended period of time (typically weeks or
longer). An acute intake is an intake of radioactive material that occurs over a short period of
time (typically minutes to hours). Regardless of the rate at which the intake occurs, the internal

Page 5 of 12


NIOSH Energy-Related Health Research Program: Tab 8: Page 1
Previous DOE Studies

Previous DOE Studies

Under the original 1990 memorandum of understanding NIOSH assumed responsibility for
the management of a number of ongoing studies, then being conducted by four DOE
contractors: Oak Ridge Associated Universities, which became the Oak Ridge Institute for
Science and Education (ORISE); Los Alamos National Laboratory, Battelle Pacific
Northwest Laboratory, and Hanford Environmental Health Foundation. Approximately

40 research efforts were itemized in the memorandum of understanding. Ten projects were
performed by ORISE, five by Los Alamos National Laboratory, and five by Hanford
Environmental Health Foundation and Battelle Pacific Northwest Laboratory were
transferred for management by NIOSH. In most of these cases, the research efforts were
well under way by the time of the implementation of the memorandum of understanding;
therefore, NIOSH had minimal opportunity to provide scientific or technical input.

NIOSH worked with these contractors to complete the studies summarized below:

I. OAK RIDGE INSTITUTE FOR SCIENCE AND EDUCATION (ORISE)

The following studies were performed by investigators from the Center for
Epidemiologic Research of ORISE, under the leadership of Donna Cragle, Ph.D. The
analysis of the studies of two sites, X-10 and Y—12, were conducted by investigators
from the University of North Carolina, as a subcontract to Oak Ridge Associated
Universities.

Oak Ridge Nati S

1. Manuscript: Wing S, Shy CM, Wood JL, Wolf, Cragle DL, Frome EL [1991].
Mortality among workers at Oak Ridge National Laboratory.
JAMA 265(11): 1397-1402.

Summary: White males hired at the Oak Ridge National Laboratory between
1943 and 1972 were followed up for vital status through 1984
(N=8,318). Relatively low mortality compared with that in U.S.
white males was observed for most causes of death. However,
leukemia mortality was elevated in the total cohort (63% higher,
28 deaths) and in workers who had at some time been monitored for
internal radionuclide contamination (123% higher, 16 deaths).
External radiation with a 20-year exposure lag was related to all
causes of death (2.68%, increase per 10 mSv), primarily due to an
association with cancer mortality (4.94%, increase per 10 mSv).


a, eel

fener

[Effective Date: Revision No, |Document No. Page No.
September 29, 2006 i) SCA-TR-TASK1-0013 23 of 115

Site profiles were developed by NIOSH as a resource to the dose reconstructors for identifying
site-specific practices, parameter values, and factors that are relevant to dose reconstruction.
Based on information provided by NIOSH personnel, SC&A understands that site profiles are
living documents, which are revised, refined, and supplemented with TIBs as required to help
dose reconstructors. Site profiles are not intended to be prescriptive nor necessarily complete in
terms of addressing every possible issue that may be relevant to a given dose reconstruction.
Hence, the introduction helps in framing the scope of the site profile. As will be discussed later
in this report, NIOSH may want to include additional qualifying information in the introduction
to this and other site profiles describing the dose reconstruction issues that are not explicitly
addressed by a given site profile.

ORAUT-TKBS-0012-2, Rev. 01, Technical Basis Document for Oak Ridge National Laboratory } i
— Site Description (Fleming 2006b), is an extremely important document, because it provides a
description of the facilities, processes, and historical information that serve as the underpinning 4
for subsequent ORNL TBDs. \

ORAUT-TKBS-0012-3, Rev. 01 PC-1, Technical Basis Document for Oak Ridge
National Laboratory — Occupational Medical Dose (Fleming 2006a), provides an
overview of the sources, types of exposure, and the frequency of exams that workers
potentially received.

ORAUT-TKBS-0012-4, Rev. 00, Technical Basis Document for Oak Ridge National Laboratory ;
~ Occupational Environmental Dose (Bums 2004b), provides background information and
guidance to dose reconstructors for reconstructing the doses to unmonitored workers outside of
the facilities at the site who may have been exposed to routine and episodic (accidental) airborne ,
emissions from these facilities.

ORAUT-TKBS-0012-5, Rev. 00 PC-1, Technical Basis Document for Oak Ridge National
Laboratory — Occupational Internal Dose (Bollenbacher et al. 2006), presents background
information and guidance to dose reconstructors for deriving occupational internal doses to
workers.

}

i
i

i
ORAUT-TKBS-0012-6, Rev. 00, Technical Basis Document for Oak Ridge National Laboratory!
— Occupational External Dose (Burns and Mohrbacher 2004), presents background information |,

and guidance to dose reconstructors for deriving occupational external doses to workers.

Site expert interviews were conducted from February 22— March 3, 2006, in Oak Ridge,
Tennessee, with former and current ORNL employees; Bechtel-Jacobs, Inc., employees; and
Department of Energy-Oak Ridge Operations Office oversight personnel. The purpose of these
interviews was to receive first-hand accounts of past radiological control and personnel
monitoring practices at ORNL, and better understand how operations were conducted.
Interviewees were selected to represent a reasonable cross-section of production areas and job
categories. References to specific site experts have been omitted for privacy reasons. The
individuals were given the opportunity to review their interview summary for accuracy. This is
an important safeguard against missing key issues or misinterpreting some vital piece of
information. To ensure that classified information had not been included in the interview notes,



Effective Date: [Revision No. {Document No. [Page No.
September 29, 2006 0 SCA-TR-TASK1-0013 66 of 115

Lincoln, T.A., 1970, Correspondence between T.A. Lincoln and E. G. Ammermann dated
September 15, 1970, no subject, Oak Ridge National Laboratory, Oak Ridge, Tennessee.

Livingston, R.S. and Boch, A.L. (1952), The Oak Ridge 86-Cyciotron, Oak Ridge National
Laboratory, Oak Ridge, Tennessee, June 12, 1952.

Livingston, R.S. (1954), Electronuclear Research Division Semiannual Progress Report for
Period Ending September 20, 1964, ORNL-1795, Oak Ridge National Laboratory, Oak Ridge,
Tennessee, November 1954.

McDowell-Boyer, L. and Little, C., 2004, Technical Basis Document for the Rocky Flats Plant —
Occupational Environmental Dose, ORAUT-TKBS-001 1-4, Oak Ridge Associated Universities,
Oak Ridge, Tennessee, June 19, 2004.

McLaughlin, D.A., 2004, personal conversation discussing the operation of the WBC facility,
January 2004.

McLaughlin, D. A., 2005, ORNL Internal Dosimetry Program Technical Basis Document,
Rev. 07, Oak Ridge National Laboratory, Oak Ridge, Tennessee, December 21, 2005.

Merwin, S. E. 2004, Technical Information Bulletin — External Coworker Data for the X-10 Site,
ORAUT-OTIB-0021, Revision 00, Oak Ridge Associated Universities, Oak Ridge, Tennessee,
December 29, 2004.

Merwin, S. E., 2005, Rev. 01 (2005), Technical Information Bulletin — Interpretation of
Dosimetry Data for Assignment of Shallow Dose, ORAUT-OTIB-0017, Rev. 00, Oak Ridge
Associated Universities, Oak Ridge, Tennessee, October 11, 2005.

Millard, J., 2004, Technical Basis Document for the Mound Site -Occupational Internal
Dosimetry, ORAUT-TKBS-0016-5, Oak Ridge Associated Universities, Oak Ridge, Tennessee,
September 9, 2004.

Morgan, K.Z. and Peterson, K.M., 1999, The Angry Genie: One Man’s Walk through the
Nuclear Age, University of Oklahoma Press, Norman, Oklahoma.

Murray, W. E., 2003, Technical Basis Document for the Y-12 National Security Complex —
Occupational Medical Dose, ORAUT-TKBS-0014-3, Rev. 00, Oak Ridge Associated
Universities, Oak Ridge, Tennessee, December 15, 2003.

NCRP (National Council on Radiation Protection and Measurement) 1971, Protection Against
Neutron Radiation, NCRP Report 38, Bethesda, Maryland.

NCRP 1989, (National Council on Radiation Protection and Measurements) 1989, Medical
X-ray, Electron Beam, and Gamma-Ray Protection for Energies Up to 50 MeV (Equipment
Design, Performance, and Use), Report No. 102, NCRP, Bethesda, Maryland.


_ DOE | Energy Employees Occupational Illness Compensation Program

The South Campus Facility was originally established in 1945 to study accidental irradiation of cattle during
testing of the first atomic bomb near Alamogordo, New Mexico. The scope of this research soon included
studies of the introduction and migration of radioisotopes in the food chain as well as other agricultural
problems. The University of Tennessee Scarboro Operations Site once operated as a comparative animal
research laboratory and an agricultural experiment station. The Scarboro Operations site was one of
several government-owned facilities assigned to ORAU and ORISE in 1981

CONTRACTOR: Oak Ridge Associated Universities (1946-present)

7 - Oak Ridge National Laboratory (X-10)

Also Known As: Clinton Laboratories
State: Tennessee Location: Oak Ridge
Time Period: 1943-present.

Facility Type: Department of Energy

Facility Description: During the Manhattan project, the Oak Ridge National Laboratory (ORNL) site was
used by the University of Chicago Metallurgical Laboratory to construct the first pile semiworks - a test plant
that would move the plutonium product process from the research stage to large scale production..DuPont,
ebegan.constjuction.of the test pllenthe X-10.reactor.in-March,1943, and was ready for operations by
e-danuary 1944. A research facility designated as the Clinton Laboratories was built during the war to support
X-10 reactor attivities and included chemistry, health and engineering divisions

After the war, the laboratory was transformed from a war production facility to a nuclear research center
and changed its name to Oak Ridge National Laboratory in 1948. The Laboratory's research role in the
development of nuclear weapons decreased over time, but the scope of its work expanded to include
production of isotopes, fundamental hazardous and radioactive materials research, environmental
research, and radioactive waste disposal.

Throughout the course of its operations, the potential for beryllium exposure existed at this site, due to
berylfium use, residual contamination, and decontamination activities

CONTRACTORS: ,LIniversity.of.Chicago (1943x145); Monsanto Chemical (1945-1947); Union Carbide and
Carbon Corp. (1948-1984); Martin Marietta Energy Systems (1984-1994); Lockheed Martin Energy
Research Corp. (1994-1998); UT Battelle (2000-present)

8 - Office of Scientific and Technical Information (OSTI)

State: Tennessee Location: Oak Ridge
Time Period: 1957 - Present
Facility Type: Department of Energy

Facility Description: The Office of Scientific and Technical Information was created to serve as a federal
government repository for all technical reports pertaining to the Department of Energy and its predecessor
agencies.

9 - S-50 Oak Ridge Thermal Diffusion Plant

State: Tennessee Location: Oak Ridge
Time Period: 1944-1951
Facility Type: Department of Energy

Facility Description: The S-50 Plant at Oak Ridge was constructed in 1944 to enrich uranium feed
material for the Y-12 electromagnetic facility using a liquid thermal diffusion process. The process was
onginally developed at the Naval Research Laboratory in Washington, DC, and tested on a pilot plant level
at the Philadelphia Naval Shipyard. Located near the K-25 gaseous diffusion facility, the S-50 Plant
operated for a limited period during 1944-1945. The plant was closed in September 1945 because the
thermal diffusion process was not as efficient as the gaseous diffusion,

http://www.hss.energy.gov/healthsafety/fwsp/advocacy/faclist/showfacility.cfm

Page 3 of 5

5/23/2010



NIOSH Energy-Related Health Research Program:

Previous DOE Studies

Tab 8: Page 12

investigation of followup status, Information about these workers
was compared with consumer credit databases to determine the last
date these workers were known to be alive. The results of this part
of the study indicate that if these procedures had been applied to all
workers with unknown vital status, about 90% of these workers
would have been confirmed to be alive. About 5% of the total study

population would have remained lost to followup.

Combined U.S. Coh

Manuscript:

Hai Oak Ridge National

orator}

‘lats)

Gilbert ES, Cragle DL, Wiggs LD [1993]. Update analyses of

combined mortality data on workers at the Hanford Site, Oak Ridge
National Laboratory, and Rocky Flats Nuclear Weapons Plant.
Radiation Res 136:408-421.

Summary:

Combined analyses of mortality data for 44,943 workers from

Hanford, Oak Ridge National Laboratory, (X-10), and Rocky Flats
were undertaken to assess cancer risks associated with protracted
low-dose exposure to ionizing radiation. Of 24 cancer sites
evaluated, 12 showed positive correlations with radiation dose, and
12 showed negative correlations. Cancer of the esophagus, cancer
of the larynx, and Hodgkin’s disease showed

Oak Ridge Graphite Reactor,
code-named “X-10,” produced the
world’s first quantities of plutonium.
Oak Ridge Graphite Reactor Landmark,
Oak Ridge National Laboratory,
Tennessee. Date not provided. Photo
courtesy of the U.S. Department of
Energy.

statistically significant correlations with radiation
dose, but these correlations were likely to have

resulted from bias or chance fluctuations. Evidence

of an increase in the excess relative risk with
increasing age at risk was found for all cancer in both
Hanford and Oak Ridge National Laboratory. Both

populations showed significant correlations of all
cancer with radiation dose among those 75 years and

interpreted cautiously.

older. Although this age effect may have resulted
from bias in the data, its presence suggests that
summary risk estimates for nuclear workers be



Effective Date: [Revision No.
September 29, 2006 0

[Document No.

SCA-TR-TASK1-0013

[Page No.

15 of 115

medical program reviews documented during the early 1990s showed many sites still used chest
radiography as a general screening exam. Most workers accepted chest x-rays, even though the
job did not require it. Also, the assumption that workers in special exposure categories, such as
beryllium workers, were given chest x-rays only as part of their routine physical is not well-
documented and not consistent with special screening guidelines. The TBD applies no
conservative assumption to cover such exams.

Finding 10: Inadequate Consideration of Environmental Dose from Radionuclides Other
than J-131 and Tritium. The Occupational Environmental Dose TBD (Fleming 2006a) focuses
on onsite airborne I-131 concentration, onsite airborne concentration of MFPs, onsite airborne
concentrations of tritium, and onsite exposure rate data. Reactors’ releases and waste farms data

are not adequately considered.

ke



Special Exposure Cohort Petition U.S. Department of Health and Human Services

under the Energy Employees Occupational Centers for Disease Control and Prevention

UlIness Compensation Act National Institute for Occupational Safety and Health

OMB Number: 0920-0639 Expires: 07/31/2010

Special Exposure Cohort Petition — Form B Page 7 of 7
Public Burden Statement

Public reporting burden for this collection of information is estimated to average 300 minutes per response,
including time for reviewing instructions, gathering the information needed, and completing the form. If you
have any comments regarding the burden estimate or any other aspect of this collection of information,
including suggestions for reducing this burden, send them to CDC Reports Clearance Officer, 1600 Clifton
Road, MS-E-11, Atlanta GA, 30333; ATTN:PRA 0920-0639. Do not send the completed petition form to this
address. Completed petitions are to be submitted to NIOSH at the address provided in these instructions.
Persons are not required to respond to the information collected on this form unless it displays a currently
valid OMB number.

Privacy Act Advisement

In accordance with the Privacy Act of 1974, as amended (5 U.S.C. § 552a), you are hereby notified of the
following:

The Energy Employees Occupational iliness Compensation Program Act (42 U.S.C. §§ 7384-7385)
'(EEOICPA) authorizes the President to designate additional classes of employees to be included in the
Special Exposure Cohort (SEC). EEOICPA authorizes HHS to implement its responsibilities with the
assistance of the National Institute for Occupational Safety (NIOSH), an Institute of the Centers for Disease
Control and Prevention. Information obtained by NIOSH in connection with petitions for including additional
classes of employees in the SEC will be used to evaluate the petition and report findings to the Advisory
Board on Radiation and Worker Health and HHS.

Records containing identifiable information become part of an existing NIOSH system of records under the
Privacy Act, 09-20-147 “Occupationaj Health Epidemiological Studies and EEOICPA Program Records.
HHS/CDC/NIOSH.” These records are treated in a confidential manner, unless otherwise compelled by law.
Disclosures that NIOSH may need to make for the processing of your petition or other purposes are listed
below.

NIOSH may need to disclose personal identifying information to: (a) the Department of Energy, other federal
agencies, other government or private entities and to private sector employers to permit these entities to
retrieve records required by NIOSH; (b) identified witnesses as designated by NIOSH so that these
individuals can provide information to assist with the evaluation of SEC petitions; (c) contractors assisting
NIOSH; (d) collaborating researchers, under certain limited circumstances to conduct further investigations;
(e) Federal, state and local agencies for law enforcement purposes; and (f) a Member of Congress or a
Congressional staff member in response to a verified inquiry.

This notice applies to all forms and informational requests that you may receive from NIOSH in connection
with the evaluation of an SEC petition.

Use of the NIOSH petition forms (A and B) is voluntary but your provision of information required by these
forms is mandatory for the consideration of a petition, as specified under 42 CFR Part 83. Petitions that fail to
provide required information may not be considered by HHS.

Name or Social Security Number of First Petitione!



: Center for Environmental Health Studies
44 Farnsworth Street, Boston, MA 02210

Prostate Cancer and
Exposure to lonizing Radiation

Summary: Evidence has been recorded of an connection between cancers of the prostate and
exposure to ionizing radiation. This connection is supported by evidence from studies of nuclear workers in
England who have been exposed to ionizing radiation. The National Research Council’s, on the other hand,
has determined that the prostate is relatively insensitive to ionizing radiation. Prostate cancer is not
designated as a “specified” cancer under the Energy Employees Occupational Iflness Compensation
Program Act. Historically, prostate cancer incidence has been high for Los Alamos County while prostate
cancer mortality has been low compared to other counties in the state. Prostate cancer incidence and
mortality rates in Rio Arriba County were among the top third of New Mexico counties. Incidence means
new cases of cancer, while mortality means deaths due to cancer.

What is Prostate Cancer?

‘The prostate is a gland in a man's reproductive system. The prostate is about the size of a walnut. It is
located below the bladder. Cancer of the prostate occurs when cells of the prostate become abnormal and
reproduce without control, Tumors of the prostate that are not cancer are common. (National Cancer
Institute)

Findings of Human Health Research Studies

Human health research studies compare the patterns of disease among groups of people with different
amounts of exposure to a suspected risk factor. Below are results reported from such studies of prostate
cancer among people exposed to ionizing radiation.

All of these studies found increases and possible increases in prostate cancer among certain groups of
exposed workers. Statistically significant is a term used to mean that the connection between the health
outcome and the exposure was strong enough that it was unlikely to be due to chance. An asterisk (*) was
placed by statistically significant findings. The research included incidence studies, which look at new
cases of cancer. These can track health more quickly and accurately than mortality studies of deaths due to
cancer.

Studies of Los Alamos National Laboratory (LANL) Workers

Research conducted of LANL workers provides the most direct evidence about possible relationships
between a health problem and workplace exposures at LANL.

* — Instudies performed to date, no reported evidence of increased rates of prostate cancer in LANL
employees.

Studies of Other Nuclear Workers in the United States

The next most relevant evidence comes from studies of workers in similar occupations with the same types
of exposures. Listed below are studies that looked at prostate cancer and workplace exposures among
nuclear workers in other parts of the United States,

+ Fernald, Ohio: A possible increase in prostate cancer deaths was found in a study of 4,014 males who
were employed between 1951 and 1989, and then followed through 1989. '

. WI Liv lifornia: A possible increased incidence of prostate cancer was seen in men
employed between 1969 and 1980.”

Prostate Cancer and Exposure to Ionizing Radiation 1


Effective Date: Revision No. [Document No. |Page No.
September 29, 2006 0 SCA-TR-TASK1-0013 69 of 115

ATTACHMENT 1: NIOSH TECHNICAL DOCUMENTS CONSIDERED
DURING THE REVIEW PROCESS

Technical Basis Documents

ORAUT-TKBS-0012-1, Technical Basis Document for Oak Ridge National Laboratory —
Introduction Rev. 00, August 11, 2004 (Burns 2004a).

ORAUT-TKBS-0012-2, Technical Basis Document for Oak Ridge National Laboratory — Site
Description Rev. 01, August 30, 2006 (Fleming 2006b).

ORAUT-TKBS-0012-3, Technical Basis Document for Oak Ridge National Laboratory —
Occupational Medical Dose Rev. 01 PC-1, July 21, 2006 (Fleming 2006a).

ORAUT-TKBS-0012-4, Technical Basis Document for Oak Ridge National Laboratory —
Occupational Environmental Dose Rev. 00, May 7, 2004 (Burns 2004b).

ORAUT-TKBS-0012-5, Technical Basis Document for Oak Ridge National Laboratory —
Occupational Internal Dose Rev. 00 PC-1, May 30, 2006 (Bollenbacher et al. 2006).

ORAUT-TKBS-0012-6, Technical Basis Document for Oak Ridge National Laboratory ~
Occupational External Dose Rev. 00, August 11, 2004 (Burns and Mohrbacher 2004).

Technical Support Documents

OCAS (Office of Compensation of Analysis and Support), 2003, Tritium Calculations with
IMBA, OCAS-TIB-002, Rev 00, National Institute for Occupational Safety and Health, Centers
for Disease Control and Prevention, U.S. Department of Health and Human Services,
Washington, DC April 22, 2003.

ORAUT-OTIB-0002, Rev. 01 PC-2, (2004), Technical Information Bulletin, Maximum Internal
Dose Estimates for Certain DOE Complex Claims, Oak Ridge Associated Universities, Oak
Ridge, Tennessee, May 7, 2004 (Rollins 2004).

ORAUT-OTIB-0006, (2005), Technical Information Bulletin: Dose Reconstruction from
Occupationally Related Diagnostic X-ray Procedures, Rev. 03, Oak Ridge Associated
Universities, Oak Ridge, Tennessee, December 21, 2005 (Kathren and Shockley 2005).

ORAUT-OTIB-0017, Rev. 01, (2005), Technical Information Bulletin — Interpretation of
Dosimetry Data for Assignment of Shallow Dose, Oak Ridge Associated Universities, Oak
Ridge, Tennessee, October 11, 2005 (Merwin 2005).

ORAUT-OTIB-0018, Rev. 01, (2005), Technical Information Bulletin — Internal Dose
Overestimates for Facilities with Air Sampling Programs, Oak Ridge Associated Universities,
Oak Ridge, Tennessee, August 9, 2005 (Brackett and Bihl 2005).


Possible Overestimate of Radiation Dose

There are a number of reasons to believe that this dose estimate represents a larger dose than
true radiation dose received while working at X-10 and Y-12. The most important

reasons for this include:

© Internal doses were estimated by using claimant-favorable assumptions regarding hypo-
thetical intakes that were unlikely to have occurred. The actual internal doses received.
by would have been considerably smaller than those calculated using these

assumptions.

© The actual doses to the bladder and prostate from occupational medical X-ray procedures
are likely to be smaller than were calculated based on the maximizing assumptions used
in this dose reconstruction.

© The external on-site ambient doses estimated for are likely much larger than
any ambient doses that were unmonitored or unrecorded.

Summary
Although unmonitored for radiation.exposur likely.received on-site ambient

Jadiation and occupational medical > X-ray doses during his employment at the Oak Ridge
National Laboratory (X-10) and the Y-12 Plant. Internal dose was also applied to account for
potential unmonitored intakes of radioactive material. The total estimated dose to

was 9.222 rem to the bladder and 16.070 rem to the prostate. The reported dose is a significant

overestimate of occupational radiation dose which will support claim determination.

Attachment 1 contains the IREP dose reconstruction summary sheets that will be used by the
Department of Labor to make the final probability of causation determination of the claim.

Page 7 of 12


dose received from radioactive materials having long half-lives occurs over an extended period
of time and is, therefore, considered chronic. The internal dose to the prostate was determined
by using the dose calculated for the colon. The internal dose to the prostate is to be determined
using the highest dose calculated for any non-metabolic organ.!° However, in this case, the dose
to an organ that provides a larger dose (colon) than the highest dose to any non-metabolic organ

was used,

Employment records for were.reviewed,and.no records of bioassay monitoring
_results, were.found.-Internal monitoring programs are applied to individuals who are likely to
be exposed to radiation from internally-deposited radioactive material. Personnel who are not

selected for internal dose monitoring programs are less likely to be exposed. However, to
account for any incidental dose that may have been received but not documented, internal dose
was assigned based on a hypothetical intake assuming an intake of 28 radionuclides. This results
in an intake that greatly exceeds any possible actual intake by because this level of
activity would be expected to be detectable by workplace indicators. Also, these nuclides would
not all be found at the X-10 or Y-12 sites. The total internal dose assigned was 7.701 rem to the

bladder and 14.549 rem to the prostate.

Assigned internal doses are based on the information provided in the Technical Information
Bulletin: Maximum Internal Dose Estimates for Certain DOE Complex Claims* and the appli-
cation of assumptions that maximize the dose to the applicable organ from the radionuclides
present at a reactor site. These assumptions include assuming large intakes of uranium that

did not likely occur. The dose calculated using the stated methodology is claimant favorable
because of the low potential for intakes of radioactive material of the magnitude assumed in the
dose calculation. This potential is considered low because 0 ob title (security
inspector) and his relatively short period of employment at the sites.

Dose from Radiological Incidents

The record of the telenhone interview was evaluated carefully by the dose reconstructor. It
indicates that wore a badge but it was not certain if this was a dosimeter. It also
states that received a letter stating that he was exposed to radiation and that he may
develop bladder cancer in the future. To predict the development of a specific type of cancer in
the future is not possible, and it is evident from the records that the badge was not a dosimeter,
although it is possible that some monitoring records could not be recovered. Overestimating
assumptions were applied in this dose reconstruction to ensure that the dose given in this dose
reconstruction was greater than any actual radiation dose received by

No radiological incidents were documented in the telephone interview or the records supplied by
the Department of Energy.

Uncertainty

Point estimates (constant values) were used for organ dose input into the NIOSH-Interactive
RadioEpidemiological Program (NIOSH-IREP).

Page 6 of 12


[Effective Date: [Revision No. [Document No. [Page No.
September 29, 2006 0 SCA-TR-TASK1-0013 19 of 115

In many ways, the TBDs have done a successful job in addressing a series of technical
challenges. In other areas, the TBDs exhibit shortcomings that may influence-some dose.
steconstructions.in,a substantial manner... Major issue areas include the following:
© Insufficient data for early worker dose reconstructions

© Inadequate consideration of missed dose from secondary radionuclides and radionuclide
impurities

© Occupational exposure to radon is not fully addressed in the TBDs

¢ Insufficient characterization of the monitored workforce for beta/gamma and neutron
monitoring

© Underestimation of neutron dose when using NTA file and in developing n-p ratios
where the initial photon dose is not well characterized

e Lack of external dose assignment methodology for unmonitored workers

¢ Incomplete evaluation of medical x-ray exposures, especially in the early years

© Inadequate validation of source data used in dose reconstruction

* Concerns with reported deficiencies of air monitoring sampler locations at the site
SC&A believes that these important issues need to be effectively dealt with in any upcoming

revisions to the ORNL site profile TBDs in order that more claimant-favorable dose
reconstructions can be effectively conducted in areas where these data gaps exist.


The Occupational Environmental Dose TBD (Burns 2004b) appears to rely on emission and
measurement data; however, it does not indicate the model used for calculations. The TBD
generally discusses particle size; however, the actual particle size assumptions for assignment of
internal dose have not been provided. No consideration has been given to the deficiencies in the
stack and ambient air sampling systems; however, there is a heavy reliance on these systems to
determine unmonitored worker dose. Exposures considered are limited to I-131, H-3 (starting
1967), Kr-85, Xe-133, and mixed fission products (MFPs) (optional), while diverse
radionuclides were handled and potentially released at the site. There has been no consideration
of potential doses from the release of large uranium particles. Overall, SC&A believes that
further investigation into environmental source terms and pathways is needed.

The Occupational External Dose TBD (Burns and Mohrbacher 2004) may result in an
underestimate of neutron dose. Neutron dose is determined from neutron track emulsion type A
(NTA) film results and is modified with a correction factor. Some facility-specific neutron
energy bands are provided; however, in some facilities, the entire spectrum is essentially below
the practical 1-MeV detection limits of NTA film used in the workers’ badges. From the
information in current Occupational External Dose TBD, ORAUT-TKBS-0012-6 (Burns and
Mohrbacher 2004), it is not obvious that the dose reconstructor has sufficient detailed correction
factors/instructions available to correct for the unmonitored neutron doses resulting from
neutrons with less than 1 MeV of energy at the numerous facilities at ORNL that produced
neutron exposures through the years.

Information available for the dose reconstruction in the early. years.is limited, inadequate, and in
some cases, not available. External monitoring for 1943-1944 was limited to the use of pocket
JOnizétion chambers (PICs), with some experimental badges worn. There is a lack of clear
discussion on how these monitored and unmonitored doses are derived during this time period.
Furthermore, the Occupational External Dose TBD (Burns and Mohrbacher 2004) questions the
validity of these data. The monitoring practices for the years prior to 195] required further
investigation to determine ox :

terms of internal exposure, there was an absence of 6
Bioassay data was limited fo plutonium and strontium, although i
“Handled even prior 1.1949. ee eee

The Occupational Internal Dose TBD lacks guidance on how to assign dose to radionuclides
other than transuranics, uranium, activation products, and fission products. As indicated by site
experts, ORNL handled almost everything on the periodic table at one point or another. There
has been no screening presented to demonstrate that the secondary radionuclides, particularly
accelerator- and reactor-produced, are of no dose consequence to the workers. Although ORNL
handled uranium and radium in the early years, no consideration was given to occupational radon
exposure. Information was not provided on the activity fractions for plutonium and thorium.
Activity fractions for plutonium provide critical information for the assessment of dose from
americium as an impurity. Dose from non-traditional chemical forms of radionuclides, such as
high-fired oxides and tritides, were not considered. Finally, an adequate rationale for assumption
of Am-241 in the case of transplutonium bioassay rather than Cm-244 was not provided.


Effective Date: IRevision No. [Document No. [Page No.
September 29, 2006 0 SCA-TR-TASK1-0013 64 of 115

Davis, D.M. and Gupton, E.D., 1957, Memorandum from D.M. Davis and E.D. Gupton to J.C.
Hart, Radiation Dose in Diagnostic X-ray Procedures, March 26, 1957.

Deal, L. J., and J. C. Hart, 1949, An Explanation Concerning Personnel Monitoring Records and
Methods of Filing Prior to January 1, 1947, Oak Ridge National Laboratory, Oak Ridge,
Tennessee.

DOE (Department of Energy), 1990, Tiger Team Environment, Safety, and Health Assessment
of the Oak Ridge National Laboratory, DOE/ED-0148, U.S. DOE, Washington DC, November

1990.

Ferry, J. L., 1944, Mz [Radon] Concentrations in Warehouses at Oak Ridge, War Department,
United States Engineering Office, Manhattan District, Oak Ridge, Tennessee, March 2, 1944.

Fleming, K., 2004, Technical Basis Document for the Oak Ridge National Laboratory ~
Occupational Medical Dose, ORAUT-TKBS-0012-3, Rev. 0o, Oak Ridge Associated
Universities, Oak Ridge, Tennessee, April 20, 2004.

Fleming, K., 2006a, Technical Basis Document for the Oak Ridge National Laboratory —
Occupational Medical Dose, ORAUT-TKBS-0012-3, Rev. 01 PC-1, Oak Ridge Associated
Universities, Oak Ridge, Tennessee, July 21, 2006.

Fleming, K., 2006b, Technical Basis Document for the Oak Ridge National Laboratory — Site
Description, ORAUT-TKBS-0012-2, Rev. 01, Oak Ridge Associated Universities, Oak Ridge,
Tennessee, August 30, 2006.

Furman, J. and Lopez, T., 2004, Technical Basis Document for the Rocky Flats Plant ~
Occupational Medical Dose, ORAUT-TKBS-0011-3, Rev. 00, Oak Ridge Associated
Universities, Oak Ridge, TN., February 9, 2004.

Gillette, J.H., Beauchamp, E.E., Case, F.N., Love, L.O., and Robinson, R.A., 1962, Isotope
Division Routine Activities Report April — June 1962, ORNL-TM-360, Oak Ridge National
Laboratory, Oak Ridge, Tennessee, October 2, 1962.

Gupton E. D., 1957, Survey Measurement for the Picker R-2 X-ray machine, Correspondence
between D. M. Davis, E. D. Gupton and J. C. Hart, Oak Ridge National Laboratory, Oak Ridge,
Tennessee, March 26, 1957.

Gupton, E. D., 1969, Methods and Procedures for Internal Dosimetry at ORNL, CF-1-58, Oak
Ridge National Laboratory, Oak Ridge, Tennessee, January 1, 1969.

Hart, J.C., 1966, A Progress Report Dealing with the Derivation of Dose Data From ORNL
Personnel Exposure Records Applicable to the Mancuso Study, Central Files Number 66-1-84,
January 14, Oak Ridge National Laboratory, Oak Ridge, Tennessee.


; Special Exposure Cohort Petition ‘ U.S. Department of Health and Human Services

under the Energy Employees Occupational Centers for Disease Control and Prevention
Nness Compensation Act 07-28-10A08:15 RCVD_ National Institute for Occupational Safety and Health

OMB Number: 0920-0639 Expires: 07/31/2010
pecial Exposure Cohort Petition — Form B Page 2 of 7

Survivor information — Complete Section B if you are a Survivor or representing a Survivor.

s

B.1 Name of, Survivor:

First Name Middle initial Last Name

B.2 Social Security Number of Survivor:
B.3 Address of Survivor:

Ctrant Ant # P.O. Box
City State 7in Code

B.4 Telephone Number of Survivor:
B.5 Email Address of Survivor:
B.6 Relationship to Employee:

Go to Part GC.

Employee information — Complete Section C UNLESS you are a labor organization.
C1) Name cf Sentaeas:

First Name * Middle Initial Last Name
C.2._ Former Name of Employee (¢.g., maiden name/legal name change/other):

Mr./Mrs./Ms. First Name Middle Initial Last Name

C.3 Social Security Number of Employee:
C4 Address of Emntovee {if livina):

Street

City State Zip Code
C.5 Telephone Number of Employee: ( ) -
C.6 Email Address of Employee:

C.7 Employment information Related to Petition:
C.7a Employee Number (if known):

C.7b Dates of Employment: Start ~¥ HU
C.7¢ Employer Name: “Sone Gaal Didhabyn -C untos Ong ovr]

C.7d_ Work Site Location: ORR Bi 1AQe x-10 Pant awd VY - toa

C.7e Supervisors Name: _( UA KUL

“

Name or Social Security Number of First Petitione



fr

The evidence shows that the employee worked at the X-10 in Oak Ridge, Tennessee, from

1943 to 1944. X-10 is not a designated SEC facility. The evidence of record does not show
that you worked at another SEC location. Therefore, the employee does not qualify as a member of
the SEC.

You meet the definition of a survivor under Part B of the Act. 42 U.S.C. § 7384s(e)(3)(A). However,
a survivor is only entitled to compensation under Part B of the Act, if the employee would have been
entitled to compensation under Part B of the Act, for an occupational illness.

Part B of the Energy Employees Occupational Illness Compensation Program Act established a
compensation program to provide a lump sum payment and medical benefits as compensation to
eligible covered employees who have been diagnosed with a specific occupational illness incurred as
a result of their exposure to radiation, beryllium or silica while in the performance of duty for the
DOE and certain of its vendors, contractors and subcontractors. 42 U.S.C. § 7384 et seq.

A cancer is considered to have been sustained in the performance of duty if it was at least as likely as
not (a 50% or greater probability) related to radiation doses incurred while working at a DOE

facility. 42 U.S.C. § 7384n(b), 42 C.F.R. Part 81 LB. The dose reconstruction estimates were
performed in accordance with the Act and the NIOSH regulations. 42 U.S.C. § 7384n(d), 42 C.F.R. §
82.10. The probability of causation calculation was completed in accordance with the Act, the ‘
implementing regulations, and NIOSH regulations. 42 US.C. § 7384n(c)(3), 20 CFR. § 30.213, 42
C.F.R. Part 81.

I conclude that you are not entitled to compensation because the calculation of “probability of
causation” does not show that there is a 50% or greater likelihood that the employee’s cancers were
caused by radiation exposure received in the performance of duty at the X-10. 42 U.S.C. § 7384n(b).
Therefore, your claim for survivor benefits for the employee’s cancer: under Part
B of the Act is denied. 42 U.S.C. § 7384n(b).

Jacksonville, Florida

2

é ’
L oo
pe ~ Z-
JeanaF,LaRock __ ae
Hearing Representative. ——
njg


under the Energy Employees Occupational
Illness Compensation Act

Dear-Sir Madam;

Special Exposure Cohort Petition U.S. Department of Health and Human Services

Centers for Disease Control and Prevention
National Institute for Occupational Safety and Heaith

OMB Number: 0920-0639 Expires: 07/31/2010
Appendix — Continuation Pas

id complete as necessary.

il im i 1.1 don’t thing they have given me a fair and accurate dose
reconstruction. I know at this time- it was beginning of the program, and everything was

new, but they should have more information now- on dose reconstruction. They have

denied and denied my claim.

ive correc: and ie!

[don’t think they have any records or On his data card his employer was-
‘ione/ Webster. Stone 7 Webster constructed Y-12Z, Location of unit on the card looks

on ie Agency- Was the

Thank vou! For reading thisletter.

~_. Attach to Form B if necessary...

Name or Social Security Number of

First Petition


Effective Date: (Revision No. |Document No. Page No.
September 29, 2006 0 SCA-TR-TASK1-0013 115 of 115

References

Argall, Rowena S., 2004, Technical Basis Document for the Los Alamos National Laboratory —
Occupational Internal Dose, ORAUT-TKBS-0010-5, Rev. No. 00, December 21, 2004.

Cox, A.C., 1944, Progress Report — First Nine Months Operation of the Pilot Plant, CN-1879,
October 9.

Fix, Jack, 2004, Technical Basis Document for the Hanford Site Occupational External
Dosimetry, ORAUT-TKBS-0006-6, Rev. No. 01, January 9, 2004.

ORAU 2005, Internal Dose Overestimates for Facilities with Air Sampling Programs, ORAUT-
OTIB-0018, Rev. 01, Oak Ridge Associated Universities, Oak Ridge, Tennessee, August 9, 2005.

Rich, Bryce L. and Chew, M.H., 2006, ¥-12 National Security Complex Occupational Internal
Dose, ORAUT-TKBS-0014-5, Rev. 02, August 3, 2006.

Thornton, W.T., Davis, D.M., and Gupton, E.D., 1961, The ORNL Badge Dosimeter and its
Personnel Monitoring Applications, ORNL-3126, Oak Ridge National Laboratory, Oak Ridge,
Tennessee.


Effective Date:
September 29, 2006

‘ision No.
0

[Document No.

SCA-TR-TASK1-0013

\Page No.
70 of 115

ORAUT-OTIB-0021, Rev. 00, (2004), Technical Information Bulletin — External Coworker
Dosimetry Data for the X-10 Site, Oak Ridge Associated Universities, Oak Ridge Tennessee,
December 29, 2004 (Merwin 2004).

ORAUT-OTIB-0034, Rev. 00, (2005), Technical Information Bulletin — Internal Coworker
Dosimetry Data for X-10, Oak Ridge Associated Universities, Oak Ridge Tennessee, December
13, 2005 (Kennedy 2005).

ORAUT-PROC-0060, Occupational Onsite Ambient Dose Reconstruction for DOE Sites, Oak
Ridge Associated Universities, Oak Ridge, Tennessee, June 28, 2006 (Winslow 2006a).

ORAUT-PROC-0061, Occupational X-ray Dose Reconstruction for DOE Sites, Oak Ridge
Associated Universities, Oak Ridge, Tennessee, June 21, 2006 (Winslow 2006b).



1/7

6.

10.

QR construction Under the Energy Employees yy
(ester Illness Compensation Program Act of 2000; Final Rule, Federal

Register/Vol.67, No. 85/Thursday, May 2, 2002, p 22314.

42 CFR 81, Guidelines ‘for Determining the Probability of Causation Under the Energy
Employees Occupational Illness Compensation Program Act of 2000; Final Rule,
Federal Register/Vol.67, No. 85/Thursday, May 2, 2002, p 22296.

NIOSH, (2002) External Dose Reconstruction Implementation Guideline, Rev 1, OCAS-
1G-001, National Institute for Occupational Safety and Health, Office of Compensation
Analysis and Support, Cincinnati, Ohio.

ORAUT (Oak Ridge Associated Universities Team), ORAUT-OT: TRy0002;sTechnical, _,

Information Bulletin : Maximum Inter ‘nal Doselistimates on Certain ROE Commlexen'
RUE

ORAUT (Oak Ridge Associated Universities Team), ORAUT-TKBS-0012-3, Technical
Basis Document for the Oak Ridge National Laboratory — Occupational Medical Dose,

ORAUT (Oak Ridge Associated Universities Team), ORAUT-TKBS-0014-3, Technical
Basis Document for. the vfs 2 National Security Complex ~ Occupational Medical Dose,
i 6.

ORAUT (Oak Ridge Associated Universities Team), ORAUT-TKBS-0012-4, Technical
Basis Document for the Oak Ridge National Laboratory — Occupational Environmental

WOSTRREPOOLM aya OAe

ORAUT (Oak Ridge Associated Universities Team), ORAUT-TKBS-0014-4, Technical
Basis Document for the Y-12 National Security Complex — Occupational Environmental
Dose, Rev 00 PC-3, October 11, Semel

ORAUT (Oak Ridge Associated Universities Team), ORAUT-TKBS-0009-2, Technical
Basis Document for the K-25 Site — Site Description, Rev 00, January 12,

ORAUT (Oak Ridge Associated Universities Team), ORAUT-OTIB-0005, Technical

Information Bulletin: Internal Dosimetry Organ, External Dosimetry Organ, and IREP
Model Selection by ICD-9 Code, Rev 02 PC-1, February 10, 200%

Page 8 of 12


DOE | Energy Employees Occupational I!Iness Compensation Program

Energy Employees Occupational Iliness Compensation Program
Home | Health and Safety

Facility List

There was one record found for the facility: Clinton Engineer Works (CEW) .

hanes Smaller - Normal - Larger - You are Here: DOE > HSS > HealthSafety > FWSP

nton Enginger Works (CEW). ,

Also Known As: Oak Ridge Area

Also Known As: Oak Ridge Reservation
State: Tennessee _ Location: Oak Ridge
Time Period: 19484104

Facility Type: Depattmentof:Energye

Facility Description: In 1943, as part of the Manhattan Engineer District, the US. Government purchased
59,000 acres 12 miles west of Knoxville, Tennessee because it needed a remote location to build
production plants and laboratories to produce plutonium and enriched uranium for the atomic bomb project.
This facility was known as the Clinton Engineer Works (CEW) and was referred to generally as Oak Ridge.
The entire CEW was:bounded by security fences from February 1943 through March 1949 EW
Were the processing:plants,known'as:Y-12,:K-25.and.X-10 (GW. ORNL each of which had its own security
fence (a fence within a fence) and has been designated separately for purposes of the EEOIPCA During
this time, dane Anderson ‘Company: managed operated and maintained residences, apartment,
dormitories, guest houses, barracks, hutments, trailers, restaurants, cafeterias, buses, roads, streets,
sidewalks, garbage and sewage disposal, heating plants Aiid-more forthe: CEW#Roane. did inc wever,s
Bperaté tHe'processing:nlants\and laboratoyiess The CEW gates came down in March 1949. This meant
that people no longer needed a security clearance to enter the CEW, though clearances were still required
to enter the plants and laboratories. The fences surrounding the processing plants also remained. It was
also in 1949 that the privatization of what is today known as the City of Oak Ridge began.

CONTRACTOR: Roane Anderson

This page was last updated on June 04, 2008

http://www.hss.energy.gov/healthsafety/fwsp/advocacy/faclist/show:

Page 1 of 1



Energy Citations Database (ECD) - - Document #393995 Page 1 of 1

Energy Citations Database
ADOPT-A-DOC?
1 sHaRe Mit H.

Bibliographic Citation

Document For copies of Journal Articles, please contact the Publisher or your local public or university
library and refer to the information in the Resource Relation field.
For copies of other documents, please see the Availability, Publisher, Research Organization,
Resource Relation and/or Author (affiliation information) fields and/or Document Availability.

Title Advances in dose reconstruction at Oak Ridge

Creator/Author Hoffman, F.0. [SENES Oak Ridge, Inc., TN (United States)} ; Widner, T.E. [ChemRisk/McLaren
Hart Environmental Services, Inc., Alameda, CA (United States)}

Publication Date 1986 Jun 01

OST! Identifier OSTIID: 383095

Report Number(s) CONF-9607735-

Other Number(s) Journal 10; FILTPAO; ISSN 0017-9078; TRN: TRN: 96:006375-00684

Resource Type Journal Article

Resource Relation Journal Name: Health Physics; Journal Volume: 70; Journal Issue: Suppl.6; Conference: 41.

Annual Meeting of the Health Physics Society, Seattle, WA (United States), 21-25 Jul 1996;
Other Information: PBD: Jun 1996
Subject 56 BIOLOGY AND MEDICINE, APPLIED STUDIES {05 NUCLEAR FUELS ;99 MATHEMATICS,
COMPUTERS, INFORMATION SCIENCE, MANAGEMENT, LAW, MISCELLANEOUS;
RADIOACTIVE EFFLUENTS; EMISSION; MERCURY; MAN; RADIATION DOSES;
ENVIRONMENT; CONTAMINATION; POLYCHLORINATED BIPHENYLS; URANIUM;
HISTORICAL ASPECTS; CLINCH RIVER; OAK RIDGE RESERVATION; PROBABILITY; DATA
COMPILATION; NEOPLASMS; MONTE CARLO METHOD.
The Oak Ridge Dose Reconstruction has seven tasks: (1) releases of radionuclides from X-10
radiolanthanum processing, (2) atmospheric and aquatic discharges of mercury from Y-12, (3)
releases of PCB's from all facilities, (4) aquatic releases of radionuclides from X-10 into the
Clinch River, (5) a systematic search for classified and unclassified records of past releases (6)
releases of uranium from ail facilities, and (7) screening of contaminants and release events not
previously evaluated in the study. The contaminants, exposure pathways, and release events
requiring the most intensive analysis are identified first through screening level calculations and
then through an iterative assessment approach based on a preliminary uncertainty analysis of
more realistic sets of models and assumptions. Subjective probability distributions are developed
for uncertain model components, reflecting the present state of knowledge about true but
unknown values, and these uncertainties are propagated through to estimates of dose and health
risk using Monte Carlo simulation. This procedure is effective in identifying the components of the
dose reconstruction model of dominant importance. Efforts are focused on the review and
improvement of the set of preliminary assumptions that may significantly impact the overall
uncertainty in the final result. The results of the screening calculations and the preliminary
uncertainty analysis are compared against established decision criteria to identify the need for
resource re-allocation among tasks. To date, a 10{sup -4} life-time incidence of cancer incidence
and a hazard index of one have been proposed as a decision criterion. Decisions about
reallocation of resources among Tasks will be made by the Oak Ridge Health Agreement
Steering Pane! and the Tennessee Department of Health, which actively seek public involvement
and participation.

Country of Publication United States

Description/Abstract

Language English
Format Medium: X; Size: pp. 51-52
System Entry Date 2009 Dec 16

http://www. osti.gov/energycitations/product.biblio.jsp?query_id=1&page=0&osti_id=393... 7/21/2010


\
IONIZING RADIATION 296 \
8. LEVELS OF SIGNIFICANT EXPOSURE TO RADIATION AND RADIOACTIVE MATERIAL

(8)3 CEL A Cancer Effect Level (CEL) is the lowest exposure level associated with the onset of '
i carcinogenesis in experimental or epidemiologic studies. CELs are always considered serious { (
| effects.

(9) Chemical Form The nuclide, the chemical form (chloride, oxide, etc.) and the type of emission
(alpha or beta particle and gamma ray) is indicated in this column.

(10) Reference The complete reference citation is given in chapter 10 of the profile.


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September 29, 2006 0 SCA-TR-TASK1-0013 67 of 115

Nielson, J. M., 1958, Recommended Procedures for Tritium, Included in Various Bioassay,
Communications, Reports, and Memorandum 1957-1958, Oak Ridge Associated Universities
COC Document Ref ID 4424, August 1958.

OCAS (Office of Compensation of Analysis and Support), 2003, Tritium Calculations with
IMBA, OCAS-TIB-002, Rev. 00, National Institute for Occupational Safety and Health, Centers
for Disease Control and Prevention, U.S. Department of Health and Human Services,
Washington, DC, April 22, 2003.

Proctor, C.W. Jr., and Alguitifan, F., 2004, Technical Basis Document for the Mound Site —
Occupational External Dosimetry, ORAUT-TKBS-0016-6, Rev. 00; August 11, 2004. Oak Ridge
Associated Universities Team, Oak Ridge, Tennessee.

Quist, A.S. (2000), A History of Classified Activities at Oak Ridge National Laboratory,
ORCA-7, Oak Ridge Classification Associates, LLC, Oak Ridge, Tennessee, September 29,
2000.

Rohrig, N., 2004, Technical Basis Document for the Idaho National Engineering and
Environmental Laboratory (INEEL) — Occupational Medical Dose, ORAUT-TKBS-0007-3,
Rev. 00, PC-1, Oak Ridge Associated Universities, Oak Ridge, Tennessee, May 28, 2004.

Rollins, G. (2004), Technical Information Bulletin, Maximum Internal Dose Estimates for
Certain DOE Complex Claims, ORAUT-OTIB-0002, Oak Ridge Associated Universities, Oak
Ridge, Tennessee.

RSCR 1981, Radiation Survey Complex Report for March 1981, Building 3517, Oak Ridge
National Laboratory, Oak Ridge, Tennessee.

Rupp, A. F., and E. J. Witkowski, 1955, RaLa Production ~ 1954, Central Files 55-1-211, Union
Carbide Nuclear Company, Oak Ridge National Laboratory, Oak Ridge, Tennessee.

Stanley, W. M., 1954, Area Contamination on April 29, 1954, Inter-company correspondence to
C. E. Larson, Carbide and Carbon Chemicals Company, Oak Ridge National Laboratory, Oak
Ridge, Tennessee, April 30.

Savignac, N., 2003, Technical Basis Document for the Hanford Site — Occupational
Environmental Dose, ORAUT-TKBS-0006-4, Rev. 00, Oak Ridge Associated Universities, Oak
Ridge, Tennessee, October 15, 2003.

SC&A 2004, SC&A Standard Operating Procedure for Performing Site Profile Reviews, Rev. 0,
March 18, 2004.

SC&A 2005c, Y¥-12 National Security Complex Site Profile Review, SCA-TR-TASK1-0007, S.
Cohen and Associates, McLean, Virginia, September 19, 2005.


decision. Final determinations are made by the Department of Labor based on standards
determined by EEOICPA and its implementing regulations.

Dose Reconstruction Overview

The Office of Compensation Analysis and Support has performed a dose reconstruction for
in accordance with the applicable requirements of the Energy Employees
Occupational Illness Compensation Progtam Act. Information provided by the Department of

Labor (DOL) indicates that worked at the Oak Ridge National Laboratory (X-10)
and Y-12 Plant from 1943, througt 1944, and that he was diagnosed with
cancer in 1964 anc : cancer in 1974. Although may have also worked

at the Oak Ridge Gaseous Diffusion Plant (K-25), consideration of possible dose at that site was
discounted for this dose reconstruction since K-25 did not begin operation until 19452

During his employment at X-10 and Y-12, was employed as a security inspector
according to records received from the DOL and information provided during the telephone
interview process. Based on the interview, probably worked checking the security at

entrances and exits to buildings at X-10. Information obtained from the Department of Energy
(DOE) jndicates that he was not monitored for sadiation exposure during his employment,,

dose was 9.222 rem to the and 16.070 rem The dose was
calculated only for these organs because of the specific types of cancer associated with this
claim.

For the purposes of this dose reconstruction, radiation dose was overestimated

using maximizing assumptions related to radiation exposure and intake, based on current science,
documented experience, and relevant data. Serra PTR hy open marae
mined that, furtheraesearch and analysis will not produce.a level.of yadiation,dos ti
probability of causation of 50% or greater. In accordance with 42 CFR § 82.10(k), ‘NIOSH thas

determined that sufficient research and analysis have been conducted to consider this dose recon-
struction complete. Per the requirements of 42 CFR § 82. 10(),' only the dose incurred up to the
point of cancer diagnosis was included in this dose reconstruction.

Information Used

The primary references used in this dose reconstruction were the ORAUT Technical Information
Bulletins and Technical Basis Documents (see references). In instances in which specific .

information useful for estimating doses | "Has lacking, parameters were
selected that, maximized the dose.estimate..

In addition to the above information, the record of the computer assisted telephone interview was
reviewed carefully by the dose reconstructor. The information provided was considered in the
dose estimation process. Additional information on the evaluation of the interview is provided in
subsequent sections of this report, as applicable.

Page 4 of 12


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SCA-TR-TASK1-0013 2 of 115

September 29, 2006 0

Issues presented in this report are sorted into the following categories, in accordance with
SC&A’s review procedures:

(1) Completeness of data sources
(2) Technical accuracy

(3) Adequacy of data

(4) Consistency among site profiles
(5) Regulatory compliance

Following the introduction and a description of the criteria and methods employed to perform the
review, the report discusses the strengths of the TBD, followed by a description of the major
issues identified during our review. The issues were carefully reviewed with respect to the five
review criteria. Several of the issues were designated as primary findings, because they
represent key deficiencies in the TBDs that need to be corrected, and which have the potential to
substantially impact at least some dose reconstructions. Others have been designated “secondary
findings” to both connote their importance for the technical adequacy and completeness of the
site profile, and to indicate that they have been judged by SC&A to have relatively less influence
on dose reconstruction or the ultimate significance of worker doses so estimated.

1.1. SUMMARY OF STENGTHS

Both the internal and external dose TBDs provided an extensive history of the internal and
external monitoring program at ORNL. Ths

_and.has.plans.to.investigate exposure, to.rad s.an impurity, and tritides. Recent,
revisions to the ORNL Site Description TBD captured a number of facilities that were missed in
the original version of the site description, and provided further information on ORNL processes
and operations. One benefit of this revision was the inclusion of all buildings mentioned by site
experts as being missing from the original revision.

12 SUMMARY OF FINDINGS

Finding 1: Incomplete Dose Data for the Earlier Years. Information available for dose

reconstruction in the garly years i adequate,.or.in not available. External
beta/gamma monitoring with film id not occur until June 1944 while routine neutron
monitoring was not available until 1949. The neutron dose is reli n ‘application of a neutron-
proton (n-p) ratio to the photon dose, yet the TBD questions the dose results from 1943-1944.
Bioassay was not routinely available prior to 1949, and then only for a few radionuclides. Table
5A-2, page 39, of the Occupational Internal Dose TBD (Bollenbacher et al. 2006) provides
minimum detectable activity (MDA) values that have been determined for gross alpha, gross
beta, and 16 radionuclides found in urinalysis sampling, and gross alpha and 4 radionuclides
found in fecal sampling. A method for identifying workers and assigning missed dose for those
potentially exposed to all the assorted radionuclides for which MDAs have been determined
(Table 5A-2, page 39) is lacking in this document. No consideration was given to early issues
with significant beta exposures, which caused skin erythema. Consideration of dose from
uranium particle releases and their subsequent deposition on the skin was not evaluated in the



iDocument No. Page No.
SCA-TR-TASK1-0013 14 of 115

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0

ctive Date:
September 29, 2006

well as photon and beta doses. During these early years, an unmonitored worker could have
received dose without management or the worker being fully aware of the hazards. The TBD
needs to provide technically sound dose reconstruction procedures for assigning doses to
unmonitored workers, especially in the early years (1943—1960s), when radiation hazards were
not always recognized or effectively addressed.

Finding 6: Lack of Data Validation and Verification. The validation and verification of the
data used in dose reconstruction has not adequately been completed. There are indications that
additional bioassay data exist that are not reflected in the database obtained by ORAU for the
calculation of MDAs. For example, we became aware that the ORNL has not fully consolidated
all the occupational exposure records, indicating that some records may not be complete. Also,
the completeness and accuracy of the external dosimetry data may require further verification to
ensure field-recorded dose results were integrated into occupational exposure records (OERs).
This adds to uncertainty of these data. Finally, the environmental air sampling data ratios used in
the development of co-worker dose from Ru-106, Ce-144, and Cs-137 should be further justified.

Finding 7: The TBD Fails to Adequately Define and Assess Occupational Medical
Exposure. The current medical exposure and dose guidelines, as presented in (Kathren 2003),
go a long way in assuring that all occupational medical exposures are reasonably included in
determining the overall dose estimations for claimants. Unfortunately, the interpretation to date
by the contractor (ORAU) has not been applied too conservatively to be claimant favorable. The
occupational medical dose TBD (Fleming 2006a) assumes an interpretation that also has been
considered and applied at other sites, such as the Mound Plant and Los Alamos National
Laboratory (LANL), Paducah, and Pinellas. To this extent, the assumption that medical
procedures are limited to only one pre-employment chest x-ray and chest x-rays that are part of
routine physical exams may substantially underestimate worker medical exposure when
evaluating occupational medical exposure.

Finding 8: Techniques and Protocols Increase Uncertainty of DCFs listed in the TBD. The
Occupational Medical Dose TBD (Fleming 2006a) provides little documentation to support the
assumed techniques and protocols applied to calculate the dose, which is mainly derived from
NCRP Report 102. The TBD states that a posterior-anterior (PA) chest x-ray was typically the
only view taken. It is an undocumented assumption in the TBD that exams required only a PA
view. SC&A has inquired whether definitive protocol existed to validate that chest exams
possibly included PA views and lateral (LAT) views on a limited basis. NIOSH has
acknowledged in other TBD reviews that the lack of verifiable protocols is a generic problem at
many sites, has planned to search all available records, and will include pertinent records and
references in any future revision of this section of the TBD. The Occupational Medical Dose
TBD is also deficient in that little documentation exists to validate x-ray protocols, equipment
maintenance, and upkeep records.

Finding 9: Frequency and Type of X-ray Exposure is Uncertain. The Occupational Medical
Dose TBD in Section 3 provides no documentation or references to support the assumption that
only a limited group of workers received annual x-ray exams after 1970. To the contrary, up
until about 1985, most DOE sites performed chest x-rays almost on a voluntary basis. DOE



‘Special Exposure Cohort Petition U.S. Department of Health and Human Services

under the Energy Employees Occupational Centers for Disease Control and Prevention
lliness Compensation Act National institute for Occupational Safety and Health
OMB Number: 0920-0639 Expires: 07/31/2010

'Special Exposure Cohort Petition — FormB Page 5 of 7

Basis for Proposing that Records and Information are Inadequate for Individual Dose —
Complete Section F.

Complete at least one of the following entries in this section by checking the appropriate box and providing
the required information related to the selection. You are not required to complete more than one entry.

F.1. & IWe have attached either documents or statements provided by affidavit that indicate that
radiation exposures and radiation doses potentially incurred by members of the proposed class,
that relate to this petition, were not monitored, either through personal monitoring or through area

monitoring.
(Attach documents and/or affidavits to the back of the petition form.)

Describe as completely as possible, to the extent it might be unclear, how the attached
documentation and/or affidavit(s) indicate that potential radiation exposures were not monitored. _

Q Nou Gn Closed AD &Ce dew with. 2 Tiow obT ayn
Foom _DSZ Tyner (Not iGates That ee Det JnowiTpred
Fou Radiation LA Posuns Chana, SA'S DD LOUNM INK «

N(OSH- hes dednmimenl Tat guntn es ear ch ombal
Qnbyal QD wluly NST G20 huce 4 Woveb of Raslia Ton dose
eek bing iM OW OT let Nie AC MURAI Sh SO% OFF

F2 We have attached either dgcuments.or statements provided by affidavit that indicate that
radiation monitoring records for members of the proposed class have been Jost, falsified, or

‘oyed; or that there is no information, regarding monitoring, source, source term, or process
from the site where the employees .

(Attach documents and/or affidavits to the back of the petition form.)

Describe as completely as possible, to the extent it might be unclear, how the attached
documentation and/or affidavit(s) indicate that radiation monitoring records for members of the
proposed class have been lost, altered illegally, or destroyed.

Tha Wee Hired Ang Phe Amie, shh pia = [LIr,
Gonpisnon, Aisvid “Raou Cunt g Otro OOYUSE LY @ AU DUO
Comtsl Oba Sto Git Ong, ON Rosuntion Prowekion Stanplarsds
There Bran AU.
Werenunk SCa-(@- TASK (-GO13 -Pooe (of US — Soph [29-20%

amen — —

. Part F is continued on the following page.

Se ana RRR

Name or Social Security Number of First Petitioner:


Purpose We report the results and analysis of a one year needs assessment study
evaluating whether a medical monitoring and risk communication program is justified for former
and current workers at the Y-12 and Oak Ridge National Laboratory (ORNL).

Methods To complete this study, we used available exposure assessment data from paper
records and electronic databases and reviewed all studies that have heen completed at the plants.
We also gathered “expert” former and current workers to conduct risk mapping sessions and
focus groups to obtain in-depth information about the plants. We collected and analyzed
responses to a questionnaire that was sent to a stratified random sample of 500 former Y-12 and
ORNL workers. We obtained employee rosters and basic employment data, to the extent
available, from the contractors and other institutions,

Findings Former and current Y-12 and ORNL workers have had significant exposure to
pulmonary toxins (nickel, asbestos, beryllium, and acids), carcinogens (external and internal
radiation, asbestos, beryllium, and cadmium), renal toxins (chlorinated solvents and lead),
neurotoxins (mercury, solvents and lead), hepatotoxins (carbon tetrachloride and other solvents)
and noise. Epidemiologic studies at Y-12 and ORNL show excess rates of selected diseases,
including cancer and selected neurologic effects, Workers are concerned about the effects of |
previous exposures on their health and are very interested in a medical screening and education /
program. Former workers have good access to health care and engage in periodic health |
examinations. However, most do not believe that their primary cate providers know much about }
the exposures that they had at Y-12 and ORNL. The focus groups and questionnaire responses i
’ also provided useful guidance about how to establish effective risk communication and medical

surveillance programs.

_sescammemeon tote,

‘The target population for a medical screening program among former and current
Y-12 and ORNL workers is conservatively estimated to range from 12,000 to 20,000. This range
requires refinement, but the roster with names and addresses that would allow initiation of
screening is currently available.

Conclusion The findings of this needs assessment study support a targeted medical and
cancer surveillance and education program. This conclusion is based on 1) the evidence that
large ‘numbers of workers have had significant exposures to detrimental agents, 2) the
demonstration among Y-12 and ORNL workers of excess risk of cancer, selected neurologic
effects and beryllium-related outcomes in epidemiologic studies, and 3) the need and desire
expressed by former and current workers for a credible targeted program of medical surveillance
and education. A health protection and risk communication program should center on workers at
risk for 1) cancer, 2) chronic respiratory disease, including chronic obstructive lung disease and
the pneumoconioses, 3) kidney, liver and neurologic disease, and 4) hearing loss. These
conditions are amenable, to early intervention, amelioration, and/or primary prevention. A risk
communication delivered by a credible source will reduce uncertainty and distrust. After
participation in the proposed screening program, former and current Y-12 and ORNL workers
will have increased real knowledge about their personal health status, what is known about their
risks, and how they can promote their own health. We believe that mounting such a program in
Phase II will make a tangible contribution to the health of former and current Y-12 and ORNL
workers.


[Effective Date: [Revision No. [Document No. [Page No.
September 29, 2006 0 SCA-TR-TASK1-0013 65 of 115

Hickey, E.E., Stoetzel, G. A., Strom, D.J., Cicotte, G.R., Wiblin, C.M., and McGuire, S.A.,
1993, Air Sampling in the Workplace, NUREG-1400, Nuclear Regulatory Commission,
Washington DC.

Huang, S.F., Simpson, D.R., Podolak, L.K., and Oakes, T.W., 1984, Preliminary Radiological
Characterization of the Homogeneous Reactor Experiment No. 2 (HRE-2), Oak Ridge National
Laboratory, Oak Ridge, Tennessee.

ICRP 1982 (International Commission on Radiological Protection) 1982, Protection of the
Patient in Diagnostic Radiology, Publication 34, Pergamon Press, New York, New York.

ICRP 1990 (International Commission on Radiological Protection), 1990, “1990
Recommendations of the International Commission on Radiological Protection,” Publication 60,
Pergamon Press, Oxford, England.

ICRP (International Commission on Radiological Protection), 1994, Human Respiratory Tract
Model for Radiation Protection, Publication 66, Pergamon Press, Oxford, England.

Ijaz T., Adler, T. C., 2004, Technical Basis Document for the Y-12 National Security Complex —
Occupational Environmental Dose, ORAUT-TKBS-0014-4, Rev. 00 PC-1, Oak Ridge
Associated Universities, Oak Ridge, Tennessee, May 20, 2004.

Johnson, L. and Schaffer, D., 1994, Oak Ridge National Laboratory: The First Fifty Years,
University of Tennessee Press, Knoxville, Tennessee.

Kathren, R.L., 2003, Technical Information Bulletin: Dose Reconstruction from Occupationally
Related Diagnostic X-ray Procedures, ORAUT-OTIB-0006, Revision 02, Oak Ridge Associated
Universities, Oak Ridge, Tennessee, December 29, 2003.

Kathren, R L. and Shockley, V. E., 2005, Technical Information Bulletin: Dose Reconstruction
from Occupationally Related Diagnostic X-ray Procedures, ORAUT-OTIB-0006, Rev. 03, Oak
Ridge Associated Universities, Oak Ridge, Tennessee, December 21, 2005.

Kennedy, W. E., 2005, Technical Information Bulletin — Internal Dosimetry Coworker Data for
X-10, ORAUT-OTIB-0034, Revision 00, Oak Ridge Associated Universities, Oak Ridge,
Tennessee, December 13, 2005.

Ledbetter, J.C., 1948, Oak Ridge National Laboratory Health Physics Division Personnel
Monitoring Group, Oak Ridge National Laboratory, Oak Ridge, Tennessee, August 1, 1948.

Lincoln, T. A., and Gupton, E. D., 1958a, Radiation Dose to Gonads from Diagnostic X-ray
Exposure, The Journal of the American Medical Association, Vol. 166, pp. 233-239, January 18,
1958.

Lincoln, T. A., and Gupton, E. D., 1958b, Radiation Doses in Diagnostic X-ray Procedures,
Radiology, Vol. 71, pp. 208-215, August, 1958.


Special Exposure Cohort Petition U.S. Department of Health and Human Services
under the Energy Employees Occupational Centers for Disease Control and Prevention
tiness Compensation Act National Institute for Occupational Safety and Health

OMB Number: 0920-0638 Expires: 07/31/2010
Special Exposure Cohort Petition — Form B

Proposed Definition of Employee Class Covered by Petition — Complete Section E.
E.1. Name of DOE or AWE Facility: DR (evalao . = ~Ve
E.2 Locations at the Facility relevant to this petition:

£.3 List job titles and/or job duties of employees included in the class. In addition, you can list by
name any individuals other than petitioners identified on this form who you believe should be

included in this class:

ALG CSuards Gaal Sovrter Dany,

E.4 Employment Dates relevant to this petition:

Start (44.3 End 4

Start End
Start End

E.5 Is the petition based on one or more unmonitored, unrecorded, or inadequately monitored or
recorded exposure incidents?: @ Yes Q No
If yes, provide the date(s) of the incident(s) and a complete description (attach additional pages
as necessary):

Bet ime Sat he Worl boon tn med
ot o-Ling Spree sl tay Ra sllotuiou, On WO. oy.
Oak OO ok Ke Clin ak OOK Rosae [Fe davrot,
Lae, OW QUAD y

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Cuore Nhs Fenty Sop users Gyoek Voum be Sno
Sour fred Mra O&M J ~

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a ane We Roses, Dj erex, 0 Abate Cand Qiu Soy
Shun xhy, Satoud

Go to Part F.

za

Name or Social Security Number of First Petitio


Center for Environmental Health Studies
44 Farnsworth Street, Boston, MA 02210

Mallinckrodt, St. Louis, Missouri: A possible increase in prostate cancer deaths was found in a study
of 2,514 males employed in uranium processing between 1942 and 1966, followed-up through 1993. 2

Oak Ridge, Tennessee: A possible increase in prostate cancer deaths was found in a study of 8,375
males who were employed for at least 30 days between 1943 and 1972, and then followed through
1977,*° Similar findings in 3,763 workers who were monitored for internal contamination, followed

through 1984. °”

Oak Ridge Y-12, Tennessee: A possible increase in prostate cancer deaths was seen in a study of
7,043 males employed between 1947 and 1990, and then followed through 1990. TM

Rocky Flats, Colorado: A possible increase in prostate cancer deaths was found in a study of 5,413
males who were employed for at least two years between 1952 and 1979, and then followed through

1979.

Savannah River Si uth Carolina: A possible increase in prostate cancer deaths was seen among
salaried employees and in white males employed before 1955.

Studies of Other Nuclear Workers Worldwide
Below are studies of nuclear workers outside of the United States that looked at prostate cancer in
connection with radiation exposures.

Atomic Energy of Canada: A possible increase in prostate cancer deaths was found in a study of
8,977 men who were employed between 1956 and 1985. “°

Atomic Weapons Establishment of the U.K.: An increase in prostate cancer deaths was found in a

study of 9,389 workers who ere monitored for radiation while employed between 1951 and 1982, and
then followed through 1982.” A possible increase in prostate cancer deaths was found in an analysis of
the 3,742 workers who were monitored for internal radionuclides (This study assumed a 10 year latent
period).

Sellafield, England: An increase in prostate cancer deaths was found in a study of radiation workers
who were employed between 1947 and 1975, and then followed to 1992, when compared to non-
radiation workers.” Also, an increase in deaths due to benign prostatic hyperplasia (BPH) was found in
plutonium workers employed between 1947 and 1975, when compared to other radiation workers. >”

Atomic Ene! uthori : Risk of prostate cancer increased in men who were internally
contaminated by tritium, chromium-51, iron-59, cobalt-60 or zinc-65." Risk increased with length of
time working in contaminated areas and increasing levels of contamination.’ “ A scientist commenting
on this study pointed out that zinc-65 localizes in the prostate gland.[letters to BMJ re: Rooney #37,
#44]

Studies of Other lonizing Radiation Exposures

Studies among other groups of people who were not nuclear workers can also be significant as evidence of
possible increases in prostate cancer among those who have been exposed to ionizing radiation. Most other
research has been conducted of people exposed to atomic bombs.

Atomic Bomb Survivors: In studies performed to date there is no reported evidence of increased rates
of prostate cancer in A-bomb survivors.

Prostate Cancer and Exposure to Ionizing Radiation 2



Effective Date: [Revision No. [Document No. age No.
September 29, 2006 0 SCA-TR-TASK1-0013 68 of 115

Scalsky, E. D., 2003, Technical Basis Document for the Hanford Site - Occupational Medical
Dose, ORAUT-TKBS-0006-3, Rev. 00, Oak Ridge Associated Universities, Oak Ridge,
Tennessee, September 16, 2003.

Scalsky, E.D., 2005, Savannah River Site, ORAUT-TKBS-0003, Revision 3, Oak Ridge
Associated Universities, Oak Ridge, Tennessee, April 5, 2005.

Shockley, V.E. and Kathren, R.L., 2005, Hanford Site -Occupational Medical Dose, ORAUT-
TKBS-0006-3, Oak Ridge Associated Universities, Oak Ridge, Tennessee, April 11, 2005.

Snapp, L, M. 2003, Practical Use of Personal Air Sampling (PAS) Data in the Internal
Dosimetry Program at the Y-12 National Security Complex, RCO-2003-004, Oak Ridge,
Tennessee.

Tybout, R. A., 1944, Mz Concentrations at Clinton Warehouses, War Department, United States
Engineering Office, Manhattan District, Medical Section, Oak Ridge, Tennessee, June 13, 1944.

Warren S. L., 1944, Radon Concentrations in the Atmosphere of Manufacturing Plants and
Warehouses, War Department, United States Engineering Office, Manhattan District, Oak Ridge,
Tennessee, March 21, 1944.

Westbrook, J. L., 2005, Basis for Development of an Exposure Matrix for the Mallinckrodt
Chemical Company St. Louis Downtown Site and the St. Louis Airport Site, St Louis, Missouri,
Period of Operation, 1942-1958, ORAUT-TKBS-0005, Rev. 01, Oak Ridge Associated
Universities, Oak Ridge, Tennessee, March 10, 1005.

Widner, T. E., 2005, Technical Basis Document for the Los Alamos National Laboratory —
Occupational External Dose, ORAUT-TKBS-0010-6, Rev. 00, Oak Ridge Associated
Universities, Oak Ridge, Tennessee, May 10, 2005.

Winslow, R.C. (2006a), Occupational Onsite Ambient Dose Reconstruction for DOE Sites,
ORAUT-PROC-0060, Oak Ridge Associated Universities, Oak Ridge, Tennessee, June 28,
2006.

Winslow, R.C. (2006b), Occupational X-ray Dose Reconstruction for DOE Sites, ORAUT-
PROC-0061, Oak Ridge Associated Universities, Oak Ridge, Tennessee, June 21, 2006,

Wirth, J. E., K. Z. Morgan, and H. J. Curtis, 1945, Health Division and Biological Section of the
Research Division Report for Month Ending February 15, 1945, CH-2587, Oak Ridge National
Laboratory, Oak Ridge, Tennessee.


[Effective Date: [Revision No, |Document No. IPage No.
September 29, 2006 ) SCA-TR-TASK1-0013 9 of 115

1.0 EXECUTIVE SUMMARY

This report provides the results of an independent audit conducted by S. Cohen and Associates
(SC&A, Inc.) of the technical basis documents (TBDs) developed by the National Institute for
Occupation Safety and Health (NIOSH) that make up the site profile for the Oak Ridge National
Laboratory (ORNL). This audit was conducted during the period February 1, 2006—__
September 15, 2006, in support of the Advisory Board on Radiation and Worker Health
(Advisory Board) in the latter’s statutory responsibility under the Energy Employees
Occupational IlIness Compensation Program Act (EEOICPA) to conduct such reviews, and
advise the Secretary of Health and Human Services on the “completeness and adequacy” of the
EEOICPA program.

ORNL is located on the Oak Ridge Reservation, along with the Y-12 National Security Complex
(Y-12) and the Oak Ridge Gaseous Diffusion Plant (K-25). The main laboratory area of ORNL
is in Bethel Valley. Other ORNL research facilities are located at an adjacent site in Melton
Valley and at the Y-12 Plant (DOE 1990). The Site Description TBD (Fleming 2006b, pp. 10-
11) provides the following summary of the scope of the nuclear activities conducted at the
ORNL:

{ Since its operations began in 1943, the mission of Oak Ridge National Laboratory
(ORNL) has been to conduct research and development (R&D) and production

| missions in support of DOE and its predecessor agencies. Much of the earliest

| site work was devoted to the development and operation of the original plutonium
§ production reactor and associated chemical separation facility to test the larger

, production reactors that were being built on the Hanford Site. The Graphite

| Reactor produced gram quantities of plutonium and later fission products [e.g.,

» radioactive lanthanum (RaLa)]; other types of radioactive materials were

4 separated in other site facilities. Waste control technologies during early site :
" operations were in their infancy, and much of the current knowledge of transport _':
5 of radionuclides in the environment was obtained during this time. The ability to

: detect, identify, and quantify radiation types and exposures were progressing 4
} along with new technologies being discovered in radioisotope ‘production, Much
4 of the information gained during the early years at ORNL was used for the design
| of future U.S. Atomic Energy Commission (AEC)/DOE facilities and detection
systems. Waste radioactive material was released from early site operations as
gaseous, liquid, and solid effluents with little or no pretreatment. Methods were
later developed to capture many of the contaminants at their source and to reduce
overall plant emissions. In some cases, this increased direct exposures to
individuals in the immediate area and created locations in which incidents and
spills occurred.

4
i
§

5

During the more than 60 years of operations at the site, facilities have been
constructed, operated, decontaminated, and decommissioned based on need. i



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September 29, 2006 0 SCA-TR-TASK1-0013 13 of 115

TBD. For 1944-1947, the TBD relies on air sampling data; however, very little information is
provided related to its collection and analysis. Further evaluation should be provided to make
sure this approach is bounding for unmonitored acute and chronic intakes.

Finding 2: Inadequate Consideration of Missed Dose from Other Radionuclides. Although
it acknowledges their existence, the Occupational Internal Dosimetry TBD ORAUT-TKBS-
0012-5 (Bollenbacher et al. 2006) does not adequately address potential doses from secondary or
so-called “exotic” radionuclides. The focus of the TBD is on “radionuclides likely to produce a
measurable internal dose,” including uranium, activation products, fission products, and
transuranics. Numerous radionuclides were handled at ORNL ranging in quantities from
fractions of a gram to kilograms. Radionuclides for which co-worker dose is assigned included
Strontium, uranium, plutonium, Am-241, Cs-137, Ce-144, and Ru-106 (Kennedy 2005).
Potential exposures to reactor- and accelerator-produced radionuclides have not been adequately
considered. The TBD does not try to ascertain when radionuclides were present, in what
quantities they were handied, and whether there were suitable methods available for monitoring
these radionuclides.

Finding 3: Problems with Neutron Doses. In view of several statements made in the
Occupational External Dose TBD (Burns and Mohrbacher 2004), the use of NTA film to monitor
neutron doses at ORNL raises several areas of concern. For example, page 23 of the TBD
mentions that neutron energy spectra and neutron exposure data before the late 1980s is sparse,
and that information is particularly lacking for many of the reactors that operated at ORNL early
in its history. If n-p values are used instead of NTA dose records, these concerns are still valid,
because using n-p values depend on a detailed knowledge of the gamma and neutron doses, and
neutron energy spectra at each work location as a function of time.

Finding 4: Lack of Information Concerning Selection of Workers for Badging. The
Occupational External Dose TBD (Burns and Mohrbacher 2004) does not provide sufficient
details concerning who was badged and when, to ensure that workers were sufficiently
monitored to allow for technically sound dose reconstruction. Page 11 of the TBD states that
initially only employees required to work in restricted areas more than 3 days per week were
issued beta-gamma monitoring, and that as late as 1956, there were no strict enforcement policies
concerning the wearing of monitoring badges. Apparently, the workers that entered restricted
areas only 1 or 2 days per week did not received badges or any dose of record. Table 6-2, page
16, of the TBD provides a list of the characteristics of dosimeters from 1944 to present worn by
radiation workers at ORNL, but does not describe what defined a radiation worker. The TBD
needs to further refine who was (and was not) monitored and how those selections were made in
order to be able to determine the adequacy of the dose records.

Finding 5: Lack of Dose Assignment Procedure for Unmonitored Worker. The
Occupational External Dose TBD (Burns and Mohrbacher 2004) does not provide a defined
procedure to assign dose to unmonitored workers. Section 6.5.1 briefly mentions limits of
detection (LOD) and provides Table 6-24, page 69, listing the LOD and exchange frequency as a
function of time. However, this should only be applied to the dose missed by the dosimeter worn
by a worker, not the dose missed because a worker was not badged. This applies to neutron as